October 19, 2023

The ease with which these unapproved components entered the supply chain has exposed glaring gaps in the industry's regulatory framework, prompting urgent calls for enhanced vetting processes. Is there a better way?

Better Vetting is not the answer to a safer supply chain

In a startling revelation, the aviation industry finds itself entangled in a massive fraud, exposing the infiltration of thousands of counterfeit engine components into global airline fleets.

Recently, Bloomberg reported on the a little-known distributor, AOG Technics Ltd. Based in London, it stands accused of peddling fake engine parts with forged documentation, raising significant concerns about the efficacy of the airline industry's vetting mechanisms.

Find the full article here: Fake Parts Found on Boeing, Airbus Jets Plague Airlines - Bloomberg // Oct-11-23

The ease with which these unapproved components entered the supply chain has exposed glaring gaps in the industry's regulatory framework, prompting urgent calls for enhanced vetting processes.

As investigations unfold, it becomes clear that the aviation sector is grappling with the aftermath of a breach that extends across major carriers worldwide. The incident not only highlights vulnerabilities in the supply chain but also emphasizes the critical need for a different approach to enforce safety in the supply chain.

This incident sheds light on the longstanding issue of self-regulation within the aviation parts distribution market. Historically, the industry has relied on meticulous record-keeping and safety protocols. However, the AOG scandal exposes the limitations of these practices and underscores the necessity for a more robust framework.

The scandal also reignites discussions surrounding the vulnerability of the aviation sector to counterfeit parts, a concern that dates back to the 1990s:

The FAA released a voluntary program in 1996 for parts sellers to agree to audits and other checks by industry organizations in order to accredit their quality practices. The idea was to address a lack of documentation and traceability plaguing distributors at the time, without further straining the FAA’s already limited resources.

But audits may not catch fake parts that slip by, and can’t catch outright forgery.

“Almost three decades later, bogus parts continue to pose possible safety risks. And as if to illustrate the point, CFM made another, more troubling discovery: having reviewed nearly 600 of its material suppliers, it, too had been directly duped by AOG.”

(Ghost in the Machine: How Fake Parts Infiltrated Airline Fleets, Bloomberg)

This approach, while common and currently the standard for the industry, is most troubling if it is an accurate description to how the industry plans on addressing the fake parts problem in the future:

“What you need to do is know that your supply chain, the providers you’re dealing with, are reputable,” said Willie Walsh, director general of the International Air Transport Association. “It’s like anything: know who your partner is, know their track record, that they know who their partners are and that the chain is secure.”

(Ghost in the Machine: How Fake Parts Infiltrated Airline Fleets, Bloomberg)

Even reputable suppliers can be duped or scammed, quality assurance problems may falter, or worse, bad actors may gain access to your systems with intent to cause harm.

A better way forward: the “Zero-Trust” supply chain.

A "Zero-trust" approach to the supply chain is gaining traction as a strategic paradigm to mitigate risks and enhance security. This concept revolves around the fundamental assumption that no entity, whether internal or external, is automatically trusted. Every aspect of the supply chain, from suppliers to distributors, undergoes continuous scrutiny and verification.

A Zero-tust approach revolves around several key aspects:

Enhanced Vigilance:

A "Zero-trust" mindset encourages organizations to remain vigilant and skeptical at every stage of the supply chain. This constant scrutiny can help identify irregularities and potential fraud, preventing the entry of counterfeit or unauthorized components.

Continuous Monitoring: Implementing a "Zero-trust" model involves continuous monitoring of activities and entities within the supply chain. This proactive approach allows for real-time detection of anomalies, making it harder for fraudulent activities to go unnoticed over an extended period, as seen in the AOG Technics scandal.

Strict Access Controls: The "Zero-trust" philosophy emphasizes strict access controls, limiting access only to necessary individuals or entities. This reduces the likelihood of unauthorized parties introducing fraudulent components into the supply chain.

Data Integrity and Validation: Verifying the integrity of data and documentation is a key aspect of the "Zero-trust" approach. In the case of the aviation scandal, forged paperwork played a significant role. A meticulous validation process would help ensure that all documentation, especially certificates and purchase orders, is authentic.

Supplier Vetting and Audits: A "Zero-trust" approach involves thorough vetting of suppliers and periodic audits. This ensures that suppliers adhere to stringent quality and security standards.

Centralized Repository: Maintaining a centralized repository for documentation, as suggested by the "Zero-trust" approach, allows for easier tracking and verification. This could significantly reduce the chances of fraudulent paperwork slipping through the cracks, as was the case in the distribution of counterfeit aircraft components.

Crisis Response Preparedness: A "Zero-trust" model promotes the development of robust crisis response mechanisms. In the event of a security breach or the discovery of fraudulent activities, organizations are better equipped to respond swiftly and effectively, mitigating the potential impact on operations and safety.

“The temptation to cut corners won’t go away any time soon. A post-Covid shortage of both parts and labor has dramatically crimped aircraft availability, putting additional pressure on airlines and maintenance shops — and creating a fertile ground for opportunists.”

(Ghost in the Machine: How Fake Parts Infiltrated Airline Fleets, Bloomberg)

The answer is not simply more trust, more vetting, or more paperwork. We need to move to a “prove it” mentality with the tools, frameworks and collective buy-in to make a viable.